(i) Hon’ble Supreme Court's judgment in the case of Commissioner of Customs, Mumbai vs. Virgo Steels [2002 (141) ELT 598 (SC)] &

Waiver of statutory notice: procedural notice can be waived and does not negate jurisdiction to recover escaped duty.

Section 28's requirement to issue notice is a procedural protection personal to the addressee that may be waived; jurisdiction to recover escaped duty stems from the levy provision, so procedural noncompliance may render proceedings voidable but does not oust recovery jurisdiction. Separately, compounded levy schemes constitute distinct regulatory regimes, and general time-limit provisions for ordinary excise recovery do not automatically apply to such special schemes.